CMS Releases RFI on HIE’s

The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health IT (ONC) have published a joint request for information asking industry stakeholders for suggestions on what more, or less, the federal government should be doing to advance clinical information exchange.

With several health IT and care coordination programs between them, the agencies say the RFI is meant to find the best ways to accelerate the business case for exchanging information. In 2011, according to CMS, 40 percent of hospitals electronically sent laboratory and radiology data to providers outside their organization. However, only 25 percent of hospitals could exchange medication lists and clinical summaries with outside providers and only 31 percent of physicians were exchanging clinical summaries with other providers.

In the RFI, CMS and ONC are asking stakeholders for comment on a number of issues, among them:

“What changes in payment policy would have the most impact on the electronic exchange of health information, particularly among those organizations that are market competitors?

“To what extent do current CMS payment policies encourage or impede electronic information exchange across health care provider organizations, particularly those that may be market competitors?

“What CMS and ONC policies and programs would most impact patient access and use of their electronic health information in the management of their care and health?”

The RFI also outlines some of the options the agencies are considering to expand HIE, within current programs and statutory authority, “through a combination of incentives, payment adjustments, and requirements that collectively result in a more coordinated, value-driven health care system over the next 1 to 3 years and beyond.” The Affordable Care Act, the agencies say, “has created new opportunities to align current and new policies in a way that provides a compelling business and patient care case to providers to change culture and exchange clinical data with all providers across the health care spectrum.”

“We introduced many concepts of interoperability in Stage 2 and expect that the Medicare and Medicaid EHR Incentive Programs criteria for Stage 3 of meaningful use will include requirements for advanced interoperability,” the agencies write. “As other value-based payment programs evolve, they might include a greater emphasis on HIE as either a requirement for participation, receipt of incentive payments, or avoidance of payment adjustments.”

The agencies are especially interested in improving HIE around transitions of care, and in spurring medical IT adoption beyond traditional hospital and physician settings. Currently, less than six percent of long-term acute care hospitals, rehabilitation hospitals and psychiatric hospitals have basic electronic health record systems, according to the agencies — just as about 30 percent of all Medicare beneficiaries being discharged from acute care settings are ending up in up in rehabilitation hospitals.

The agencies say there are a variety of options they’re considering to encourage HIE in those settings and more broadly for Medicaid and Medicare beneficiaries.

The ACA’s section 1115 waiver is one way HHS is letting states experiment with strategies for improved Medicaid programs, while offering financial support that can help fund IT. The Medicaid EHR Incentive Program can also help states develop and sustain HIEs, with certain expenditures being eligible for 90 percent federal matching, although the agencies note that “CMS approval of funding for HIE infrastructure costs requires assurances that other payers and providers will bear an appropriate share of the costs, risks and governance.”

The agencies also want to encourage “beneficiary engagement in their care” by expanding patient access to personal health information and fostering “better electronic communication between beneficiaries and their health care team.” In addition to trying to build out the Blue Button PHR app, CMS says it’s considering building incentives for PHR use into demonstration programs.